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Comment for AB 32 Scoping Plan (scopingpln08) - 45 Day.

First NameRoger
Last NameGrable
Email Addressrgrable@manatt.com
AffiliationManatt, Phelps and Phillips
SubjectVote No on AB 32 Scoping Plan Burden on Housing
Comment
I am writing to express strong concern about the proposed
recommendation within the AB 32 Scoping plan to target a reduction
of 5 million metric tons (MMT) annually of greenhouse gases from
Regional Transportation-Related Targets. In factI have heard that
the Board is being asked by some to increase that target to a
significanlty higher number.


I strongly urge the Board NOT to increase the Regional
Transportation-Related Targets any further. There is really no
scientific support to even justify greenhouse gas (GHG) reduction
targets from passenger vehicles at the proposed 5 MMT level. 
Anything more than this is merely a negotiating posture but those
with other agendas and ignore the potential economic consequences
on the housing industry, the need for housing in the state and the
related economic consequences that would occur.  


The recently-enacted Senate Bill 375 sets out the process to
determine the actual regional transportation-related GHG targets.
That process needs to be given deference and allowed to work. It
should not be preempted at this early stage by unilateral action by
the Board.


Homebuilders have a vested interest in the success of SB 375 and
AB 32. Homebuilders also have a vested interest in assisting the
state out of its current and profound economic malaise. Imposing
out-of-proportion burdens on California’s homebuilders and
consumers will neither help our struggling economy nor
realistically achieve our AB 32 goals. 


I strongly urge you not to increase the Regional
Transportation-Related Targets any further.




Attachment
Original File Name
Date and Time Comment Was Submitted 2008-12-03 17:43:15

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